Bank’s sanctions policy and AML/CFT measures 

AML/CFT and Financial Crime Prevention Policy

IDBank CJSC (hereinafter referred to as the “Bank”) is committed to maintaining a robust framework to prevent money laundering, terrorist financing, proliferation financing and other financial crimes. The Bank aims to ensure that its products, services and delivery channels are not used for illicit purposes.

The Bank has a zero-tolerance approach to knowingly establishing or maintaining business relationships, or conducting transactions, for persons who are involved in or reasonably suspected of being involved in money laundering, terrorist financing or other predicate offences.

For this purpose, the Bank takes all reasonable and proportionate measures to identify, assess, mitigate and manage ML/TF risks in accordance with its internal policies, the requirements of the Central Bank of the Republic of Armenia (CBA), and applicable international standards, including the recommendations of the Financial Action Task Force (FATF).

The Bank has established an Anti-Money Laundering and Financial Crime Prevention Policy, which sets out the principles, procedures and internal controls for identifying, managing and mitigating financial crime risks arising from the Bank’s activities.

The Bank applies a risk-based approach, taking into account the nature of customers, geographic exposure, transactions, products, services and delivery channels. This approach enables the Bank to apply controls proportionate to the level of risk identified.

Within this framework, the Bank implements the following measures:

• Regularly assesses financial crime risks associated with customers, geographic exposure, transactions, products, services and delivery channels;
• Applies risk-based Customer Due Diligence (CDD) procedures, including Enhanced Due Diligence (EDD) in higher-risk cases;
• Monitors customer transactions and behaviour to identify unusual or suspicious activity;
• Identifies suspicious transactions and submits mandatory reports to the Central Bank of the Republic of Armenia in accordance with applicable legal and regulatory requirements;
• Implements measures to prevent the misuse of the Bank’s products and services for criminal purposes;
• Refuses to establish or continue business relationships where financial crime risks cannot be adequately managed;
• Maintains information relating to customers and transactions in accordance with applicable legal and regulatory requirements;
• Provides mandatory training on AML/CFT and sanctions requirements to all employees.

The above measures are not exhaustive. The Bank may implement additional controls in accordance with applicable laws, regulations and internal policies.

To comply with applicable legislation, regulatory requirements and internal policies, the Bank may refuse transactions, decline to establish or continue business relationships, freeze assets, or take other appropriate measures where financial crime risks are identified.

The Bank’s internal policies may establish requirements that are stricter than those required by applicable legislation. Accordingly, the Bank may decline to provide services to certain customers or process certain transactions where the associated risks are considered unacceptable.

The Bank also recognizes the evolving nature of financial technology and permits certain transactions involving crypto-assets, provided that such transactions comply with the legislation of the Republic of Armenia and the regulations of the Central Bank of the Republic of Armenia.

Customers may, at their own risk, conduct transactions for the purchase of crypto-assets for investment purposes, exchange crypto-assets, or make and receive payments for goods and services, where such activities are permitted under the laws of the country in which the transaction is conducted.

Prohibited and Restricted Activities

The Bank’s AML/CFT framework is based on the Law of the Republic of Armenia “On Combating Money Laundering and Terrorist Financing,” regulations of the Central Bank of the Republic of Armenia and other applicable legal acts.

The Bank prohibits establishing business relationships with customers presenting an unacceptably high level of risk, including, but not limited to, shell banks and persons subject to terrorism-related sanctions. The Bank does not maintain anonymous or fictitious-name accounts, or accounts identified solely by numbers, letters or other symbols. The Bank also does not maintain accounts involving bearer shares.

The Bank refuses transactions or declines to establish business relationships where a customer fails to provide the information or documentation required by the Bank.

The Bank prohibits establishing business relationships and conducting one-off transactions with citizens and residents of countries and territories identified by the FATF as High-Risk Jurisdictions subject to a Call for Action, as well as with legal entities and organizations registered, incorporated or operating in such countries and territories. The same restriction applies to citizens, residents, legal entities and organizations of countries and territories included in the United Nations Security Council sanctions lists.

The Bank prohibits transactions and business relationships with foreign legal entities engaged in the production, processing or operation of nuclear energy, persons engaged in “red-light” business activities, foreign legal entities engaged in the manufacture or trade of weapons and ammunition, and companies engaged in the sale, transportation or processing of marijuana.

The Bank also does not provide services to companies engaged in cryptocurrency services or money transfer activities where a licence is required in their jurisdiction of operation but the relevant licence has not been obtained.

The provision of services by foreign companies operating in the territory of the Republic of Armenia for the purpose of conducting transactions involving crypto-assets is not permitted where such companies do not have a subsidiary, representative office or branch in the Republic of Armenia holding the relevant authorization from the Central Bank of the Republic of Armenia.

The Bank may also restrict or prohibit certain activities where the associated risks are considered unacceptable.

In addition, the Bank applies enhanced controls to higher-risk customers, including customers engaged in extensive cash-intensive activities, Politically Exposed Persons (PEPs), correspondent relationships, and customers with links to high-risk jurisdictions or territories, among others. In such cases, the Bank applies Enhanced Due Diligence, enhanced monitoring and additional approval processes for establishing business relationships.

During the establishment of a business relationship or the updating of customer information, where information from publicly available sources, applicable watchlists and/or widely used information databases identifies a potential match with another person, but the Bank cannot determine whether the match relates to the customer, the Bank may request additional information or documentation from the customer to determine whether the potential match is a false positive. If the requested information or documentation is not provided, or where the match is confirmed as a true match, the Bank may terminate or decline to establish the business relationship.

Sanctions Compliance

The Bank is committed to complying with applicable international sanctions and restrictive measures.

As a responsible participant in the international financial system, while taking into account its interests, security and business continuity, the Bank follows the sanctions regulations and lists of the United Nations Security Council, European Union, United Kingdom and United States.

The Bank maintains internal controls to prevent transactions or business relationships that could result in sanctions violations. Where necessary, the Bank may refuse transactions, terminate business relationships, freeze assets or take other appropriate measures.

The Bank refuses transactions or declines to establish business relationships where a customer fails to provide the information or documentation required by the Bank.

The Bank prohibits establishing or continuing business relationships with, or conducting transactions involving, individuals or legal entities designated on applicable sanctions lists. This also applies where, under the 50% ownership rule established by the relevant sanctions authority, a legal entity is considered subject to sanctions due to its ownership by a sanctioned person, even if the legal entity itself is not expressly designated.

The Bank prohibits establishing or continuing business relationships with, or conducting transactions involving, individual customers who are simultaneously citizens and residents of comprehensively sanctioned countries or territories. The same restriction applies to legal entities registered or operating in comprehensively sanctioned countries or territories and/or whose owners, founders or ultimate beneficial owners are simultaneously citizens and residents of such countries or territories.

The Bank prohibits transactions involving comprehensively sanctioned countries or territories.

The Bank may decline to establish or continue a business relationship or process a transaction where such activity does not comply with the Bank’s risk appetite or presents a high risk of sanctions evasion. Repeated violations of the Bank’s sanctions policy by a customer may constitute grounds for termination of the business relationship.

Where necessary, the Bank may request additional documents and/or information from a customer. If the requested information or documentation is not provided, or where a sanctions match is confirmed as a true match, the Bank may terminate or decline to establish the business relationship.

   Wolsfberg Group Anti-Money Laundering Questionnaire